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This official website is maintained by the Notice Administrator under the supervision of Co-Lead Counsel for the members of the Class in DZ Reserve et al. v. Meta Platforms, Inc., Case No. 3:18-cv-04978, which is pending in the United States District Court for the Northern District of California, San Francisco Division.

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Notice

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BASIC INFORMATION ABOUT THE LAWSUIT

Plaintiffs in the lawsuit allege that Facebook made misrepresentations and omissions when providing the Potential Reach metric to advertisers. Plaintiffs allege Facebook inflated its potential advertising reach to consumers and charged artificially high premiums for ad placements. Facebook’s Potential Reach was expressed as a number of people. Plaintiffs allege that Potential Reach metric was not actually an estimate of people, but an estimate of “accounts.” Plaintiffs allege that, because the number of unique accounts and unique people were different, this led to an inaccurate representation of how many people Class Members’ advertisements could reach. Plaintiffs allege that the discrepancy between people and accounts made the Potential Reach number inaccurate.
Plaintiffs bring claims for damages under California law for (1) fraudulent misrepresentation and (2) fraudulent concealment.

Facebook denies all of Plaintiffs' allegations. While Facebook no longer provides Potential Reach estimates to advertisers, Facebook maintains that it provided accurate and informative disclosures about Potential Reach when it was available, including that it informed advertisers that despite Facebook’s efforts to deduplicate accounts, there were some users who had multiple accounts which may have impacted Potential Reach estimates. Facebook denies that any Class Member has been damaged. Facebook did not charge advertisers based on Potential Reach estimates but instead charged based on actual results which were provided in real time to advertisers.

No money or benefits are available now because the case is not resolved. There is no guarantee that money or benefits will ever be obtained. If they are, you will be notified about how to ask for a share. If the litigation is resolved, and you have not excluded yourself, you may not be given another opportunity to do so.

DETERMINING IF YOU ARE A MEMBER OF THE CLASS

The following are members of the Class:

  • Subject to the exclusions below, United States residents (including natural persons and incorporated entities) who, from August 15, 2015, to October 27, 2021 (“Class Period”), paid for the placement of at least one advertisement on Facebook’s platforms, including the Facebook and Instagram platforms, which was purchased through Facebook’s Ads Manager or Power Editor.

The following are NOT members of the Class:

  • Purchasers whose advertisements all met at least one of the following five criteria: (1) advertisements purchased pursuant to agreements other than Facebook’s Terms of Service or Statement of Rights and Responsibilities; (2) advertisements purchased using only non-lookalike Custom Audiences as the targeting criteria; (3) advertisements purchased using Reach and Frequency buying; (4) advertisements purchased with the objectives of canvas app engagement, canvas app installs, offer claims, event responses, page likes, or external; and (5) advertisements for which Facebook provided a Potential Reach lower than 1,000.
  • Defendant, any entity in which Defendant has a controlling interest, and Defendant’s officers, directors, legal representatives, successors, subsidiaries, and assigns. Any judge, justice, or judicial officer presiding over this matter and the members of their immediate families and judicial staff.

IF YOU DO NOTHING

As a Class Member, unless you exclude yourself from the Class in the manner described in the section below titled “EXCLUDING YOURSELF FROM THE CLASS,” you will be bound by any judgment entered or settlement reached in this lawsuit, whether favorable or unfavorable. Unless you exclude yourself, you will not be able to file a lawsuit or be part of any other lawsuit asserting claims against Facebook concerning or relating to the claims and factual allegations that were or could have been raised in this action.

EXCLUDING YOURSELF FROM THE CLASS

If you do not want to be part of the Class and want to keep your right to sue Facebook relating to the allegations concerning the alleged conduct described in this Notice, then you must take steps to remove yourself from the Class. This is called excluding yourself, or “opting out.” The Court will exclude any person who asks to be excluded. If you exclude yourself, you will not be eligible to receive any payment from future settlements or judgments in this lawsuit, and you will not be bound by any judgment rendered for or against Facebook.

To exclude yourself from the Class, you must either send a request by mail or through the case website stating that you wish to be excluded from the Class in DZ Reserve et al. v. Meta Platforms, Inc., Case No. 3:18-cv-04978.

If you mail your Request for Exclusion, it must be postmarked no later than July 28, 2025, to:

Facebook Potential Reach Class Action
Attn: Exclusions
c/o A.B. Data, Ltd.
P.O. Box 173105 
Milwaukee, WI  53217
info@FacebookPotentialReachLawsuit.com

If you mail your Request for Exclusion, be sure to include your name, address, telephone number, and signature.

To request exclusion through the case website, click on the Request for Exclusion tab. The Request for Exclusion must be submitted no later than July 28, 2025.

No. Unless you exclude yourself, you give up the right to sue Facebook for the claims in this case. You must exclude yourself from the Class to be able to bring your own, separate lawsuit(s) against Facebook. Remember, the exclusion deadline is __________, 2025. In the event the lawsuit resolves, you may not be given another opportunity to exclude yourself from the Class.

THE LAWYERS REPRESENTING YOU

Yes. The Court has appointed lawyers to represent the members of the Class. These lawyers are called Class Counsel. The following lawyers are lead counsel in representing the Class:

Geoffrey A. Graber

Andrew N. Friedman

Karina G. Puttieva

Madelyn Petersen

Jenna Waldman

COHEN MILSTEIN SELLERS & TOLL PLLC

1100 New York Ave. NW

Suite 800

Washington, DC  20005

 

Theodore J. Leopold

Leslie M. Kroeger

COHEN MILSTEIN SELLERS & TOLL PLLC

11780 U.S. Highway One

Suite N500

Palm Beach Gardens, FL 33408

 

Eric A. Kafka

COHEN MILSTEIN SELLERS & TOLL PLLC

88 Pine Street

14th Floor

New York, NY 10005

 

Charles Reichmann

LAW OFFICES OF

CHARLES REICHMANN

 Yale Circle

Kensington, CA 94708-1015

 

In the event of a judgment against Facebook at trial or by settlement, Class Counsel will ask the Court to approve and award attorneys’ fees and expenses. The amount of these fees and costs, if any, will ultimately be determined by the Court.

You do not need to hire your own lawyer because Class Counsel is working on behalf of the Class. You may, however, hire your own lawyer to represent you if you wish. If you hire your own lawyer, he or she must file a Notice of Appearance. If you hire your own lawyer, you will have to pay for that lawyer on your own.

THE TRIAL

Class Counsel will have to prove the Plaintiffs’ allegations at trial. The Court has scheduled a jury trial to begin on October 14, 2025. The trial will be held in the United States District Court, Northern District of California, located at Courtroom 11, 19th Floor, 450 Golden Gate Avenue, San Francisco CA 94102. During the trial, a Jury and the Judge will hear all the evidence to help them reach a decision whether Plaintiffs or Facebook is right about the allegations in the lawsuit. There is no guarantee that Plaintiffs will win or that they will be able to get money for all or some of the members of the Class.

You do not need to attend trial. Class Counsel will present the case for the Plaintiffs, and Facebook will present the defense. You or your lawyer are welcome to attend at your own expense.

If the Plaintiffs obtain money or benefits as a result of the lawsuit, you will be notified about how to participate. We do not know how long this will take.

GETTING MORE INFORMATION

This site contains a summary of relevant Court papers. You can review relevant Decisions and Orders and additional information about this action on the Court Documents page. You may also contact the Notice Administrator by mail, email, or phone using the following contact information:

Facebook Potential Reach Class Action
c/o A.B. Data, Ltd.
P.O. Box 173105 
Milwaukee, WI  53217
info@FacebookPotentialReachLawsuit.com
888-206-2123

PLEASE DO NOT CONTACT THE COURT OR THE COURT CLERK’S OFFICE TO INQUIRE ABOUT THIS CASE.